Statutory compensation under special acquisition law cannot be reopened by importing Land Acquisition Act remedies or later awards.

The Supreme Court treated the Requisitioning and Acquisition of Immovable Property Act, 1952 as a self-contained code for requisition, acquisition and compensation, distinct from the Land Acquisition Act, 1894. Section 28A of the 1894 Act could not be imported by implication to reopen compensation under the 1952 Act, because a substantive right to redetermine compensation must be expressly conferred by statute. Agreements fixing compensation under Section 8(1)(a) of the 1952 Act were contractual in nature and could not be unilaterally reopened merely because later awards granted higher compensation to other landowners.

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Issues: Whether Section 28A of the Land Acquisition Act, 1894 could be invoked for redetermination of compensation in acquisitions made under the Requisitioning and Acquisition of Immovable Property Act, 1952, and whether an agreement fixing compensation under Section 8(1)(a) of the 1952 Act could be reopened on the basis of an award granted to similarly situated landowners.

Analysis: The 1952 Act was treated as a self-contained code governing requisition, acquisition, and compensation. The mode and manner of determining compensation under that Act were held to be distinct from the Land Acquisition Act, 1894, and the two enactments were not regarded as pari materia. Since Section 28A is a substantive statutory remedy for reopening compensation only where the statute so permits, it could not be imported by implication into proceedings under the 1952 Act. The Court also held that where the parties had entered into agreements under Section 8(1)(a), their rights were contractual and could not be reopened unilaterally merely because a later award enhanced compensation for other lands. A right to re-determine compensation must be expressly provided by statute and cannot be read in by implication.

Conclusion: Section 28A of the Land Acquisition Act, 1894 was not applicable to acquisitions under the Requisitioning and Acquisition of Immovable Property Act, 1952, and the appellants had no legal right to compel reopening of the compensation agreement.

Ratio Decidendi: A substantive right to reopen concluded compensation under a special acquisition statute must be expressly conferred by that statute, and cannot be imported by analogy from the Land Acquisition Act, 1894 or read into a contractual settlement by implication.

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